Environmental Impact and Social Risk Management Policy

The Environmental Impact and Social Risk Management Policy of the Company is based on the following basic principles:

1) Defining environmental and social strategic goals, such as the design of new financial products aimed at environmen tal and social sustainability;

2) Inclusion of considerations of environmental and social risks in all directions of the Company’s activities;

3) Exclusion of customer financing in cases where the latter’s activity does not comply with the Company’s Risk Management principles;

4) Ensuring a safe and healthy working environment for the Company’s employees, free from physical, chemical, biological and radiation hazards;

5) Presentation of environmental and social risk management issues to Company staff, clients and other stakeholders;

6) Improving the environmental impacts and social performance of the Company’s loan portfolio through enhanced risk management;

7) Continuous development of knowledge of Company personnel to identify environmental and social risks.

The environmental and social risk classification categories of the Company are: (i) High, (ii) Substantial, (iii) Moderate and (iv) Low risk according to the new Environmental and Social Standard (ESS) published by the World Bank in October 2018.

An Environmental and Social Risk Management System has been developed to ensure the effective implementation of the Policy and proper assessment of environmental and social risks for the Company’s Clients.

Assessment of environmental and social risks is an integral part of the Company’s financing process to Clients. It is the joint responsibility of the Company’s credit and risk management teams to ensure the latter’s effective implementation.

The Company’s ESG Committee oversees the implementation of the Environmental and Social Risk Management System in the Company, monitors progress and is accountable to the Company’s Board. The ESG Committee is responsible for the approval of short-term and long-term development plans for the Company’s ESG risk management, as well as for monitoring its implementation.

As an integral part of the Policy, the Company also defines the activities or areas of activity that the Company cannot finance: Exclusion List.